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G7+ Coalition Issues Alert on Russian Oil Price Cap Evasion Methods and How to Report Violations

On February 1, 2024, the G7+ Coalition (consisting of the G7, the European Union, and Australia) published an Oil Price Cap (OPC) Compliance and Enforcement Alert (the “Alert”), identifying notable OPC evasion methods and...more

“There are Cops on the Beat”: DOJ’s Procurement Collusion Strike Force Leader Emphasizes Criminal Antitrust as Top Enforcement...

On September 14, 2023, Daniel W. Glad — Director of the Procurement Collusion Strike Force (“Strike Force”) for the Department of Justice’s (“DOJ”) Antitrust Division — gave remarks as the keynote speaker for the Virginia Bar...more

SBA Issues Interim Guidance After Ultima Decision Finds 8(a) Program Violates Equal Protection

On July 19, 2023, in Ultima Services Corp. v. U.S. Department of Agriculture, the U.S. District Court for the Eastern District of Tennessee enjoined the U.S. Small Business Administration (SBA) from determining federal...more

Departments of Justice, Commerce and Treasury Issue Tri-Seal Compliance Note on Voluntary Self-Disclosure of Potential Violations

On July 26, 2023, the U.S. Department of Justice’s National Security Division, U.S. Department of Commerce’s Bureau of Industry and Security, and U.S. Department of the Treasury’s Office of Foreign Assets Control issued a...more

U.S. Department of Justice and Partners Increasing Enforcement of Sanctions and Export Controls

It has been a little more than a year since Russia’s invasion of Ukraine, and the war continues to rage. In an effort to deter the Russian government and weaken its military capabilities, the United States has imposed...more

Analysis of DOJ’s FY 2022 FCA Statistics and the Mixed Signals Therein

Earlier this month, the U.S. Department of Justice (DOJ) announced that it recovered over $2.2 billion under the False Claims Act (FCA) in Fiscal Year 2022. That is a steep drop from last year’s near-record $5.7 billion haul...more

Supreme Court Signals Interest in Clarifying Pleading Requirements in False Claims Act Suits

The Supreme Court (Court) will soon decide whether to take up a critical (and long-running) issue concerning applicability of Federal Rule of Civil Procedure 9(b) pleading standards in False Claim Act (FCA) suits. To satisfy...more

New Revelations in Ukraine Lead to Tightening Global Sanctions

As the world watched in horror over the atrocities occurring in the war zones of Ukraine this week, global leaders re-doubled their efforts to bring increasing sanctions pressure to bear on Russian industry, the Russian...more

Western Companies Starting to Feel Impact of Russian Sanctions

As we approach the thirty day mark since the United States, and other Western countries began imposing a series of rigorous sanctions on the Russian economy and key components thereof, we are starting to see real evidence of...more

DOJ Ramps up Resources and Renews Focus on Combatting COVID-19 Related Fraud in 2022

On March 10, 2022, the U.S. Department of Justice (DOJ) announced the appointment of Associate Deputy Attorney General Kevin Chambers to serve as the Director for DOJ’s COVID-19 Fraud Enforcement Task Force. In remarks...more

FinCEN Encourages “Increased Vigilance” and Highlights Red Flags for Evasion of Russian Sanctions including Use of Virtual...

The Financial Crimes Enforcement Network (FinCEN) has issued an alert encouraging all financial institutions to be “vigilant” against efforts by their customers to evade recent sanctions and other restrictions imposed by the...more

Federal Framework for Digital Asset Regulation Comes into Focus

On March 9, 2022, President Biden signed an Executive Order on Ensuring Responsible Development of Digital Assets (“Executive Order”) to mobilize the federal government to develop a strategy for digital assets, intending to...more

DOJ Settles First False Claims Act Enforcement Action Since Launch of Civil Cyber-Fraud Initiative

On March 8, 2022, the U.S. Department of Justice (DOJ) announced a $930,000 settlement with Comprehensive Health Services, LLC (CHS) for alleged violations of the False Claims Act (FCA). This settlement marks DOJ’s first...more

DOJ Launches “Task Force KleptoCapture” in Response to Russian Invasion

Last week, the U.S. Department of Justice (DOJ) announced the launch of an aggressive interagency law enforcement task force, Task Force KleptoCapture. The Task Force represents another U.S. enforcement initiative in response...more

U.S. and Allies Significantly Expand Sanctions and Related Restrictions on Russia and Belarus

Over the last several days, the United States and allies in North America, Europe, and Asia have announced a sweeping expansion of the sanctions levied against Russia and affiliated entities and individuals in the wake of...more

Analysis of DOJ’s 2021 FCA Statistics and the Trends Therein

Last week, the U.S. Department of Justice (DOJ or Department) announced that it recovered over $5.6 billion under the False Claims Act (FCA) in Fiscal Year 2021. That is a massive headline haul that is second only to the...more

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